Background
Christian Witt pled guilty to being a prohibited person in possession of a firearm in violation of federal law. He appealed the district court’s denial of his pretrial motion to suppress evidence, arguing the detective lacked reasonable suspicion or probable cause to initiate the stop. The detective had stopped Witt’s vehicle after observing a large spiderweb crack across the windshield while patrolling near the Surfwood Apartments in Rapid City, South Dakota.
The court’s reasoning
The court reviewed the district court’s findings of fact for clear error and legal conclusions de novo. The court noted that a traffic violation creates probable cause to stop a driver. The court examined photos of the cracked windshield which showed the crack originated between the center and passenger side and spiderwebbed across the entire windshield. The court concluded the crack significantly impaired Witt’s vision by interfering with his ability to observe traffic and pedestrians and to safely turn. The court further held that the detective’s belief that the windshield did not comply with the statute was objectively reasonable.
What it means going forward
This decision reinforces that officers may rely on an objectively reasonable belief that a traffic violation has occurred to justify a stop, even if their testimony regarding the specific legal standard is not perfectly precise. It also confirms that visual evidence of a significant windshield crack can establish probable cause under South Dakota law.
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